This judgment deals with the validity of reassessment notices issued u/s 148 of the Income Tax Act...

This judgment deals with the validity of reassessment notices issued u/s 148 of the Income Tax Act between July and September 2022, in light of the Tax Ordinance and the Supreme Court's decision in Ashish Agarwal. The key points are: The Court clarified that directions issued under Article 142 are not binding ratios but supplementary measures to achieve complete justice. It exercised this power in tax matters where Revenue actions were not per law. The Court deemed reassessment notices issued under the old regime between April 1 and June 30, 2021, as show-cause notices under the new regime in Ashish Agarwal, balancing assessee and Revenue rights and avoiding further appeals. The legal fiction created a deemed stay on proceedings till the Re..... .....

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